For the purposes of reading of this document we clarify that the terms “British American Tobacco,” “the Group” and the “British American Tobacco Group” are used to refer to British American Tobacco p.l.c. and the group of companies constituting its direct and indirect subsidiaries worldwide, including BAT BRASIL.
1.1. Through its Applications and the performance of its SERVICES, BAT BRASIL requests and obtains personal data from its USERS. Essentially, the personal data are sent by the USERS when signing up the APPLICATIONS and/or using the SERVICES offered by BAT BRASIL.
1.3. If the USER wishes to purchase additional products or services offered in the APPLICATIONS, BAT BRASIL will collect additional data, which will be used solely for the purpose of making payment for the contracted SERVICES.
1.4. The personal data provided may be stored on servers located abroad – preferably in the United States, in view of the cloud services we use – and shall only be provided to third parties as provided for under the Law and/or by court order. By using the SERVICES AND APPLICATIONS, the USER expressly agrees to such international data transfer.
1.6. By using the APPLICATIONS and accessing BAT BRASIL’S website, certain information regarding the USER, such as the Internet protocol (the “IP address”), operating system, time spent on the APPLICATIONS, among other information, will be stored by BAT BRASIL or by a company contracted for this purpose, which shall be contractually obliged to comply with the confidentiality and secrecy duties. These logs may be used, for example, for traffic analysis and use of the APPLICATIONS. If they do not wish to provide this data, the USER may set their Internet browser to disable cookies, being aware that, in this case, the disabling of cookies may cause the features of the APPLICATIONS and of BAT BRASIL’s Website to work improperly.
1.7. In the performance of its activities, BAT BRASIL does not process any personal data of people under age. Should BAT BRASIL identify any data regarding people under age, they will be immediately excluded.
2.1. For the performance of the SERVICES, BAT BRASIL shall not share, lend or exchange the USER’ personal data with third parties for marketing or commercial purposes.
2.4. BAT BRASIL values the privacy of its USERS and uses the personal data provided by them for the following purposes:
2.5. In the event of any order from public authorities requiring access to the information stored by BAT BRASIL, the relevant USER and subject data shall be notified so that they can adopt the defense measures they deem appropriate.
2.6. In any case, the data collected through the APPLICATIONS and arising from the SERVICES shall be stored only for the period required by the relevant regulations or until it is necessary for the purposes for which they were collected. The data will then be deleted, as provided for under the law, subject to the following cases: (i) compliance with any legal or regulatory obligation by BAT BRASIL; (ii) study by any research authority, whenever possible guaranteeing the personal data anonymization; (iii) transfer to third party, provided that the data processing requirements set out under the law are respected; or (iv) exclusive use BAT BRASIL, access by any third party being prohibited, and provided that the data are anonymized.
3.1. BAT BRASIL shall not be responsible for the personal data processing carried out by third parties due to the use of systems, applications, websites and platforms in general that are their own. The processing performed by third parties shall be governed by their relevant Privacy Policies.
4.1. The USERS guarantee that the data provided are true and current, undertaking to update them whenever there is any modification therein.
4.2. The USERS may access, correct or update their data at any time, as well as request the definitive deletion of their data from BAT BRASIL’s servers or exercise any other rights provided for under Art. 18 of Law No. 13,709/18 through the Service Channel indicated in item VI hereof, being aware that in the event of deletion of their data they will no longer be able to access the features and services provided.
5.1. BAT BRASIL has in force appropriate technical and organizational security measures aimed at (i) protection against unauthorized access to stored data and backups; and (ii) preventing unauthorized changes, disclosures and/or destruction of any information held by BAT BRASIL.
5.2. We restrict access to information to people who need this information to provide the necessary support to the USERS, or to ensure the best operation of our digital services, products and/or tools. These individuals are bound by the duty of confidentiality and subject to disciplinary punishment, including termination of the employment contract and criminal prosecution in case of failure to comply with this obligation.
5.3. If the USERS suspect any misuse, loss or unauthorized access to their personal information, they shall immediately contact BAT BRASIL through the service channel provided for in item VI.
6.2. The USERS undertake to keep updated in their registration their e-mail address, through which the communications directed to them by BAT BRASIL will be made.